In a recent article, a former Brookings fellow proposed an alternative to subsidized lunches as a measure of students at risk. According to Matthew Chingos, now director of Urban Institute's Education Policy Program, a handful of states are using new methods of data analysis for identifying economically disadvantaged students as an alternative to the long-used free or reduced-price lunch (FRL) measure.

The problem, Chingos wrote, is that FRL eligibility has evolved under the "community eligibility" provision, which promises to reduce paperwork for schools in high-poverty areas by eliminating applications and simply delivering breakfasts and lunches to all students. Currently, he said, one in five schools offers free lunches to their students under the provision.

As a result, the FRL designation becomes meaningless for research and policy tied to reporting of student achievement. That's a problem when districts attempt to identify specific subgroups of students as required under ESSA for accountability systems. "Continuing to use FRL to identify economically disadvantaged students in community eligibility schools means either saying that all students are eligible, which would violate the spirit of ESSA, or surveying families to find out who would be eligible on an individual basis, which would be costly and burdensome," Chingos suggested.

As an alternative, Chingos suggested looking to states such as Delaware, Massachusetts, New Mexico and Tennessee, as well as Washington, D.C., which have begun applying new methods for identifying those disadvantaged students based on family participation in such programs as the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), Medicaid and the foster care system or because they're homeless. No forms needed, he pointed out. The states doing this create linkages to data systems maintained by various agencies to "directly certify" students for FRL.

As an example, he offered, in D.C., among those schools where all students receive a free lunch, the at-risk percentage actually varies between 23 percent and 95 percent.

Chingos warned, however, that states undertaking this effort will have to "ensure the privacy and confidentiality of student records" and may have to upgrade their data systems or amend regulations or laws restricting how data is used.

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